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But, it you take that approach, once the plan terminates, none of the 401(a)(9) regulations would apply and there would be no RMD regardless of what happens in the rest of the 2016 calendar year. I agree there is no clear guidance. I think a more reasonable approach is to consider the regs to apply through the end of the calendar year that includes the final distribution. Then, if someone who didn't have an RMD requirement before their distribution is paid retires during the calendar year, they are treated the same way they would be if the plan continued and part of their distribution becomes their RMD. In our case, after being told he could roll over the entire distribution, the participant decided to take part of his distribution directly and roll over the remainder. The amount to be received directly is sufficient to cover a 2016 RMD if one were to apply.

Get the boss of the "HR person" on the phone, and say the words "fiduciary violation" slowly and clearly.

That's 22 / 23 / 24. The following day, 4/9/16 was 22 / 32 / 42

I (still) say no. There was an old thread on this and somebody named Bird had a convincing argument; last word and no rebuttals.